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SPCC & CCP Issues

SPCC & CCP Issues. Jim Roewer APPA E&O Conference April 12, 2006. Spill Prevention Control & Countermeasures (SPCC) Regulations. SPCC Rule Revisions. SPCC Amendments Published July 17, 2002 Federal Register (67 Fed. Reg. 47042)

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SPCC & CCP Issues

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  1. SPCC & CCP Issues Jim Roewer APPA E&O Conference April 12, 2006

  2. Spill Prevention Control & Countermeasures(SPCC) Regulations

  3. SPCC Rule Revisions • SPCC Amendments Published July 17, 2002 Federal Register (67 Fed. Reg. 47042) • Original Proposal October 22, 1991; Amendments Proposed February 17, 1993 & December 2, 1997) • Effective Date August 16, 2002

  4. Compliance Timeframes • Revisions to plans must be made by February 17, 2003, implemented by August 18, 2003 • New facilities must have plan before commencing operations • Acquired facilities considered already operational and must have plans in place

  5. Compliance Timeframes • Revisions to plans must be made by February 17, 2006, implemented by August 18, 2006 • New facilities must have plan before commencing operations • Acquired facilities considered already operational and must have plans in place

  6. Oil-filled Equipment & Small Facility SPCC Rule • ANPR September 2004 • Proposed Rules December 2005 • Extension of Compliance Deadlines to October 31, 2007 (or 1 year from Final Rule) • Tailored SPCC Program for Electrical Equipment & Small Facilities • Comment Deadlines January (extension) and February (substance) 2006

  7. Threshold Determination • Applies to facilities that “could reasonably be expected to discharge oil … into or upon navigable waters ….” (40 C.F.R. §§112(a)(1) & (b)) • Man-made features cannot be considered • Volume threshold >1320 gallons • Containers <55 gallons exempted

  8. Electrical Equipment • Oil-filled equipment is subject to rule • Equipment volume included in threshold determination • Equipment excluded from “bulk storage container” definition, avoids requirements for: • bulk storage secondary containment • corrosion protection • periodic integrity testing • inspection

  9. Containment/Diversionary Structures • All regulated facilities required to provide containment and/or diversionary structures or equipment to prevent a discharge of oil • Diversionary structures: • dikes, berms, retaining walls • curbing • culverting, gutters, drainage systems • weirs, booms, other barriers • spill diversion ponds • retention ponds • sorbent materials

  10. Electrical Equipment • Oil-filled electrical equipment from which no discharge in last 10 years & is subject to monitoring &inspection does not need general secondary containment (waiver of PE’s determination of impracticability determination) • Discharges from Electrical Substations ~20/Year

  11. Small Facilities • Facilities with cumulative volumes <10,000 gallons still need SPCC plan, but • SPCC Plans do not need to be certified by a PE • Potential reduction in cost/administrative activities • May limit flexibility (e.g., determination of impracticability, environmental equivalence)

  12. SPCC “Loose Ends” Rulemaking • Will address other issues arising from 2002 SPCC Amendments • Expected to address differentiation of petroleum v vegetable/animal oils as per the Edible Oil Regulatory Reform Act (“EORRA”) • EPA announced plans for proposal in 2006, but ….

  13. SPCC Summary • Compliance Deadlines Extended to October 31, 2007 • Proposed Relief for Small Facilities (<10,000 gal) • Proposed Relief from Secondary Containment for Electrical Equipment • “Loose Ends” Rule, including Differentiation

  14. Coal Combustion Product (CCP) Management Issues

  15. CCP Regulatory Background • August 1993 & May 2000 Non-Hazardous Regulatory Determinations • Rulemaking Schedule: • CCP Disposal • August 2006 Proposal; Final Rule August 2007 • Mineplacement • October 2007 Proposal; Final Action 2008

  16. CCP Management Issues • EPA’s Concerns: • Groundwater Monitoring • CCP Placement in Sand & Gravel Mines (Non-engineered Sites) • Dry Handling of CCPs • Mill Rejects Management • Mineplacement • Utilization

  17. Regulatory Options: CCP Disposal • National Subtitle D Standards • Application of Industrial D Guidance • Implementation of USWAG CCP Action Plan • Status Quo (State Regulatory Control) • DOE/EPA Report on New Facilities June 2006

  18. Regulatory Options: CCP Mineplacement • RCRA Standards • SMCRA Standards • Status Quo (State Regulatory Control Under SMCRA and/or RCRA Authorities) • NAS Report on Mineplacement February 2006

  19. CCP Management Challenges • Damage Case Resolution • Survey of New Disposal Facilities • Subtitle D Regulations • Enviros’ Lawsuits • Mercury Rules/Multi-Pollutant Legislation

  20. Hg & Multi-Pollutant Impact on CCPs • Increase in FGD generation • Decrease in CCP generated due to decrease in coal consumption • Impact on ash quality due to SCR, low-NOX burners, Hg control • Challenge to CCP utilization

  21. CCP Issues Summary • Regulatory Future Uncertain • Non-hazardous Status of CCPs Critical • Disposal & Mineplacement Regulations • CAA Implementation Will Affect CCPs • Regulatory Status Unlikely to be Affected • Impact on Utilization Possible • Utilization Activities Key

  22. Jim Roewer 202/508-5645 jim.roewer@uswag.org Questions?

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